An overview of regulatory issues that affect the development of new waste treatment technologies Page: 36 of 64
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2.1.5 Subpart X
On December 11, 1987, EPA added a new Subpart X to 40 CFR 264 to estab-
lish standards for miscellaneous units not covered by other TSD-permitting
standards. By setting generic standards for nonconventional units, EPA hoped
to create a better-defined framework for processing TSD permits for innovative
technology. However, these technologies must still receive a full Part B
permit and, thus, encounter the time and expense involved in that permitting
process. Additionally, EPA has had little experience preparing Subpart X
permits, and most authorized states have yet to promulgate regulations for
Subpart X. Significant time delays can be expected if RDDT&E technologies are
to acquire Subpart X permits.
2.1.6 Mobile Treatment Units
EPA published a proposed rule on June 3, 1987, that would have simplified
permitting procedures for transportable treatment technologies. Under exist-
ing procedures, mobile treatment units must undergo a full Part B permitting
process at every operating location. As will be discussed in Chapter 4, this
effectively limits the attractiveness of mobile technologies to CERCLA onsite
cleanups where RCRA permits are not required. Publication of a final rule
apparently has fallen low on EPA's list of priorities.
2.1.7 Subpart Y
When EPA issued its treatability study regulations on July 18, 1988, it
stated an intent to develop a new Subpart Y to 40 CFR 264 to establish per-
mitting standards for experimental facilities that test multiple types of
waste treatment technologies. EPA has not yet proposed a rule in this area.
2.2 RELEVANT PROVISIONS OF THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984
The three most significant changes to the federal hazardous waste program
established by the HSWA are
• certification that all hazardous waste generators have a waste min-
imization program in place
• creation of a land disposal restrictions program to require pre-
treatment of hazardous waste prior to land disposal
2.10
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Kuusinen, T L; Siegel, M R; Williams, T A & Powell, J A. An overview of regulatory issues that affect the development of new waste treatment technologies, report, July 1, 1991; Richland, Washington. (https://digital.library.unt.edu/ark:/67531/metadc1093979/m1/36/: accessed July 18, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.